Migration agent practices combine high-value client disbursements, professional service fees, government registration costs, and — in some practices — trust account obligations. The bookkeeping complexity comes not from volume but from the need to correctly classify what is the agent's revenue, what is a pass-through, and what attracts GST. Getting this wrong leads to over-reporting income, incorrect BAS lodgements, and potential trust account non-compliance.
Department of Home Affairs Visa Application Charges: Agent vs. Principal
The most significant item passing through a migration agent's books is the Department of Home Affairs (DOHA) visa application charge. These charges are substantial:
- Temporary Skill Shortage (TSS, subclass 482): up to $3,115 per applicant
- Employer Nomination Scheme (subclass 186): $4,770 per applicant
- Business Innovation and Investment (subclass 188): up to $9,185
- Global Talent visa (subclass 858): $4,770
- Certain employer-sponsored streams for large corporate sponsors can involve multiple applicants simultaneously, with total DOHA fees exceeding $60,000 for a single project
The bookkeeping treatment of these fees depends entirely on whether the agent acts as agent or principal:
Agent arrangement (most common): The migration agent collects DOHA fees from the client, holds the funds, and remits them directly to DOHA in the client's name. Under this arrangement:
- The DOHA fee collected is a liability (money held for the client) — not the agent's revenue
- The remittance to DOHA extinguishes the liability
- Only the professional service fee charged by the agent is revenue
- No GST applies to the DOHA fee component (see below)
Principal arrangement (rare): If the agent contracts with the client to provide a "visa outcome" and bears the obligation to pay DOHA regardless of the client's willingness, the DOHA fee may be the agent's own cost of delivering the service. In this case, the full amount charged to the client (including DOHA fees) is gross revenue, and the DOHA payment is an expense. This is commercially unusual and most agents operate as agents, not principals.
GST on DOHA Visa Application Charges
Commonwealth government visa application charges are not subject to GST. Visa charges are a government levy imposed under the Migration (Visa Application) Charge Act 1997 — they are a statutory obligation, not a supply of goods or services under the GST Act.
The agent does not charge GST on the DOHA fees they collect and remit. Even where the agent technically advances DOHA fees (paying DOHA before recovering from the client), the reimbursement of that advance is not subject to GST.
Tax invoices issued to clients must clearly separate:
- Professional service fees (+ GST at 10%)
- DOHA visa application charges (GST-free)
- Any other disbursements (GST status depends on the underlying supply)
Commingling these items on a single invoice without the GST breakdown is a common compliance failure.
GST on Migration Professional Services
A registered migration agent's consulting fees, application preparation fees, lodgement fees, review and appeal representation fees, and employer-sponsorship advisory fees are all taxable supplies under the GST Act. GST at 10% applies to all professional service income.
There is no GST exemption for migration advisory services — unlike health services (which are GST-free) or financial services (which are input-taxed), migration advice is a standard professional service.
For an agent with annual professional fee income of $600,000 (exclusive of DOHA disbursements):
- GST output = $60,000 (entered at BAS label G1 and 1A)
- Input credits on practice running costs (office, software, CPD) are fully claimable
OMARA Registration and CPD: Deductibility
The Office of Migration Agents Registration Authority (OMARA) — now operating as a unit within the Department of Home Affairs — requires registered migration agents to:
- Pay an annual registration renewal fee (currently around $1,500 for full registration)
- Complete a minimum of 10 CPD hours per year (under the Migration Agent Regulations 1998)
Both costs are deductible under s.8-1 of the ITAA 1997 as expenses incurred in carrying on a business for the purpose of producing assessable income.
GST on OMARA fees: Government registration charges imposed by OMARA are not subject to GST — they are a statutory levy, not a taxable supply. Code these as GST-free.
CPD costs: Seminars, conference registrations, and online courses from private providers typically carry GST. Claim the ITC and deduct the cost (net of ITC if the agent is GST-registered).
Trust Account Obligations
Migration agents who hold client funds between collection and DOHA submission — particularly where there is a gap of days or weeks — may be subject to trust account obligations depending on the state or territory in which they practise and how their business is structured.
Strictly, federal migration law does not impose solicitor-style trust account requirements on migration agents (unlike lawyers, who are governed by state legal profession legislation). However, agents who are also qualified lawyers, or who operate in states where legal practitioner trust account rules have been interpreted broadly, should take legal advice on their obligations.
Best practice for agents handling significant client funds:
- Hold DOHA fee advances in a dedicated client funds account (separate from the operating account)
- Maintain a client funds ledger showing each client's balance
- Never use client funds for operating expenses
- Reconcile the client funds account to the individual client ledger balances monthly
Even without a formal legal obligation, this practice structure protects the agent from allegations of misappropriation and simplifies audit evidence if an OMARA review occurs.
Professional Development Expenditure
Migration agent CPD costs are deductible. Agents who travel interstate or internationally for OMARA-approved conferences may also claim:
- Travel and accommodation costs (s.8-1 ITAA 1997, with the private use apportionment rules in s.900-30 applying to combined business-personal trips)
- Conference registration fees
- Professional library subscriptions and legal research database costs (LexisNexis, Westlaw, BorderConnect training materials)
Note that costs incurred for initial education to become a migration agent (a Graduate Certificate or Graduate Diploma in Australian Migration Law and Practice) are not deductible — they are capital expenditure on a new qualification, not maintenance of an existing qualification. By contrast, a practising agent who pays for a migration law update seminar is maintaining existing professional knowledge — deductible.
End-of-Period Checklist
- Professional service fees recognised as taxable supplies with GST at 10%; DOHA visa charges excluded from GST calculation
- DOHA disbursements booked as pass-throughs (agent); liability cleared when remitted; no revenue recognised on the disbursement
- Client funds account reconciled to client-by-client ledger; reconciling items resolved
- OMARA registration fee coded as GST-free government charge; deducted as a business expense
- CPD costs deducted; ITC claimed on costs from private providers carrying GST
- Trust account (if maintained) reconciled and client ledger agrees with bank balance
- Superannuation guarantee reviewed for any contractors who are primarily providing personal labour (s.12(3) SGAA)
- BAS labels checked: G1 (taxable sales — professional fees only), 1A (GST on sales), 7 (ITC on purchases)